Revised: January 1, 2026

General Statement of Policy

Rolka Loube Saltzer LLC ("Rolka Loube", "we", "us", or "our") is a private-sector organization that administers programs and services for government entities.

This Privacy Policy applies to the following Rolka Loube Service Desks (the "Service Desk" or "Site"):

• Colorado Service Desk - Jira Service Management

• NDBEDP Service Desk - Jira Service Management

• Pennsylvania Service Desk - Jira Service Management

• TRS Contributor Service Desk - Jira Service Management

• Provider Service Desk (TRS, URD) - Jira Service Management

It explains:

• What information we may collect about you (the user)

• How we may use that information

• What information we may share with others

• How we handle information submitted through support tickets, comments, and attachments

• Your responsibilities regarding sensitive data and personally identifiable information (PII)

• Your choices and rights regarding the personal information you provide to us.

The Service Desk is provided to individuals and organizations with a legitimate business or support-related reason to contact Rolka Loube.

This Privacy Policy applies only to the Service Desk and does not govern the separate Rolka Loube payment portal or other Rolka Loube services that maintain their own privacy policies.

What Information We Collect

The Service Desk is used to submit, track, manage, and resolve inquiries, support requests, technical issues, and other business-related communications with Rolka Loube.

In providing these services, Rolka Loube may collect and use Personal Data, Business Information, Ticketing Information, Usage Data, and Cookies, as defined below.

The information collected may include:

1. Contact and Business Information

• First and last name

• Business email address

• Company or organization name

• Business telephone number

• Business affiliation or role, when provided

• Other non-sensitive business contact information reasonably necessary to address a support request.

2. Service Desk Ticketing Information

When you submit or participate in a support request, the Service Desk may collect, generate, or maintain information such as:

• Ticket number or unique request identifier

• Ticket subject or summary

• Description of the request or reported issue

• Request type or category

• Date and time of ticket submission

• Ticket status, priority, and assignment information

• Comments, replies, and related communications

• Files, screenshots, documents, and other attachments submitted in connection with the request

• Ticket updates, resolution details, and activity history

• Internal support notes or other administrative information generated in connection with processing the ticket.

3. Technical and Usage Information

The Service Desk may automatically collect certain technical information associated with access to and use of the Site, including:

• Internet Protocol (IP) address

• Browser type and version

• Device and operating system information

• Date and time of access

• Pages or features accessed

• Session identifiers

• System activity and diagnostic information

• Other technical data used for system administration, security, and troubleshooting.

4. Information Provided by Other Parties

Rolka Loube may receive information from government agency clients, authorized representatives, service providers, or other parties when reasonably necessary to investigate, manage, or resolve a support request.

We use the information collected through the Service Desk to provide support services, communicate with requesters, maintain support records, administer and secure the Service Desk, and conduct related business activities.

Some information collected through the Service Desk, including names, business email addresses, IP addresses, and ticket communications, may constitute Personal Data under applicable privacy laws.

By using the Service Desk, you acknowledge the collection and processing of information as described in this Privacy Policy.

Unless otherwise defined herein, terms used in this Privacy Policy have the same meanings as in the Rolka Loube Service Desk Terms of Use.

Sensitive Data and Personally Identifiable Information (PII)

The Rolka Loube Service Desk is not intended to receive or process sensitive personal information or unnecessary personally identifiable information.

Users must not include, enter, upload, attach, transmit, or otherwise submit sensitive data or unnecessary PII through the Service Desk.

This restriction applies to all portions of a support request, including:

• Ticket subjects and descriptions

• Support request forms

• Comments, replies, and messages

• Screenshots and images

• Documents and file attachments

• Technical logs and diagnostic files

• Email communications associated with support tickets.

Prohibited information includes, but is not limited to:

1. Social Security numbers and other sensitive personal identification numbers.

2. Government-issued identification numbers, driver's license numbers, passport numbers, or copies of government identification documents.

3. Bank account numbers, routing numbers, credit card numbers, debit card numbers, and other sensitive financial account information.

4. Passwords, access credentials, authentication tokens, security answers, private keys, API secrets, or other confidential authentication information.

5. Protected health information, medical records, and other sensitive health-related information.

6. Personal dates of birth, residential addresses, and personal contact information not reasonably necessary for a support request.

7. Sensitive information relating to customers, employees, consumers, or other third parties.

8. Confidential or regulated business records that have not been expressly authorized for submission through the Service Desk.

9. Any other sensitive information whose inclusion is unnecessary for the support request or could create an unreasonable privacy or security risk.

Permitted Information

The restriction on sensitive data does not prohibit users from providing basic business contact information reasonably necessary to submit or manage support requests, including names, business email addresses, company names, and business telephone numbers.

Data Minimization

Users should provide only the minimum information reasonably necessary to describe and resolve a support request.

Before submitting screenshots, documents, logs, or other attachments, users are responsible for reviewing the materials and removing or redacting sensitive data and unnecessary PII.

Accidental Submission of Sensitive Information

If you believe that sensitive information or prohibited PII has been inadvertently submitted through the Service Desk, you should promptly notify Rolka Loube using the contact information provided in this Privacy Policy.

Do not repeat or resubmit the sensitive information when providing this notification.

Rolka Loube may take appropriate steps to restrict access to, redact, remove, or delete such information, subject to applicable laws, legal obligations, and records-retention requirements.

Submitting sensitive information in violation of these restrictions does not make the Service Desk an authorized channel for receiving or processing such information.

Use of Cookies

We may use Cookies and similar tracking technologies to track activity on the Service Desk and maintain certain information.

Cookies may be used by Rolka Loube or the third-party technology platforms supporting the Service Desk.

You can instruct your browser to refuse Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use certain portions of the Service Desk.

Examples of Cookies that may be used include, but are not limited to:

• Session Cookies: Used to operate the Service Desk and maintain user sessions.

• Preference Cookies: Used to remember user preferences and settings.

• Security Cookies: Used for authentication, security, and the protection of user accounts and support information.

The specific Cookies used may depend on the Service Desk platform and its configuration.

Usage Data

Rolka Loube may use Usage Data to:

• Provide analysis and information to improve the Service Desk

• Monitor the usage and performance of the Service Desk

• Detect, prevent, and address technical issues

• Maintain the security and reliability of the Service Desk

• Investigate suspected unauthorized access or misuse

• Support system administration and troubleshooting.

Usage Data may be collected automatically through the Service Desk platform and its associated services.

Who We Share Information With

Information collected through the Service Desk may be shared with authorized parties when reasonably necessary to provide support services, administer programs, maintain the Service Desk, or fulfill applicable legal and contractual obligations.

Such parties may include:

1. Authorized Rolka Loube Personnel

Service Desk information may be accessed by Rolka Loube employees, contractors, or other authorized personnel who require the information to review, investigate, manage, or resolve support requests or perform related administrative and operational functions.

2. Government Agency Clients and Their Designees

Service Desk information may be shared with relevant government agency clients, including the Federal Communications Commission (FCC) or its designees, when reasonably necessary to investigate, respond to, or resolve support requests associated with programs or services administered by Rolka Loube.

Such sharing may include relevant ticket descriptions, communications, supporting documentation, and resolution information.

Information will be shared for legitimate program administration, operational, or support-related purposes, subject to applicable laws and contractual requirements.

3. Service Providers

Rolka Loube may use third-party companies or individuals to provide the Service Desk on our behalf, perform Service Desk-related services, maintain the ticketing system, or assist us in analyzing how the Service Desk is used.

The Service Desk is accessible through an Atlassian-hosted service platform. The platform provider and other authorized service providers may process or store information in connection with delivering these services.

We seek to use appropriate contractual, organizational, and technical protections for information handled by service providers, consistent with applicable requirements.

4. Legal or Regulatory Disclosures

We may disclose information when required by applicable law, regulation, court order, or other valid legal process, or under the extraordinary circumstances described below.

5. Aggregated or De-identified Information

Aggregated information that does not reasonably identify individual requesters or organizations may be used for internal reporting, service improvement, operational analysis, or publicly available reporting where appropriate and legally permitted.

Except as described in this Privacy Policy, information submitted through the Service Desk will not be disclosed for purposes unrelated to the provision, administration, or lawful operation of our services.

Use of Information

The Service Desk uses Information for several purposes, including but not limited to:

• Receiving and processing support requests

• Investigating and resolving reported issues

• Responding to questions and providing customer support

• Maintaining records of support requests and related communications

• Communicating ticket status updates, requests for additional information, and resolution notices

• Coordinating support activities with relevant Rolka Loube personnel, government agency clients, and authorized service providers

• Providing and maintaining the Service Desk

• Notifying users about changes to the Service Desk

• Allowing users to participate in interactive features of the Service Desk, where available

• Monitoring system performance and improving support services

• Detecting, preventing, and addressing technical or security issues

• Fulfilling applicable legal, contractual, administrative, and recordkeeping obligations.

Rolka Loube may retain ticket information as part of its operational and administrative records, subject to applicable retention requirements.

Security of Information

The security of your information is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure.

While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Rolka Loube may employ administrative, technical, and organizational measures designed to protect Service Desk information against unauthorized access, disclosure, alteration, or destruction.

Access to ticket information may be restricted to authorized personnel and service providers with a legitimate business or support-related need for such access.

Users are responsible for maintaining the confidentiality of their Service Desk account credentials and for ensuring that sensitive data and unnecessary PII are not submitted through support tickets or attachments.

If you believe that your Service Desk account or information has been compromised, please notify Rolka Loube promptly using the contact information below.

Data Retention

Rolka Loube may retain Service Desk information, including support tickets, communications, attachments, and associated records, for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy.

Retention may be determined by operational needs, applicable government program requirements, contractual obligations, records-retention schedules, legal requirements, and legitimate business purposes.

Certain information may also be retained when reasonably necessary to comply with legal obligations, resolve disputes, investigate security incidents, or protect the rights and interests of Rolka Loube and its clients.

Information may remain in backup systems for a period consistent with applicable backup and retention procedures.

Where appropriate and consistent with applicable requirements, information that is no longer necessary may be deleted, de-identified, or otherwise disposed of in accordance with established procedures.

Links to Other Sites

Our Service Desk may contain links to other websites that are not operated by us.

If you click a third-party link, you will be directed to that third party's website and may be subject to its Privacy Policy.

We strongly advise you to review the Privacy Policy of every website you visit.

Rolka Loube has no control over and assumes no responsibility for the content, privacy policies, or practices of independent third-party websites or services.

This provision does not limit any responsibilities Rolka Loube may have under applicable law regarding service providers that process information on its behalf.

Changes to this Privacy Policy

Rolka Loube reserves the right to modify this Privacy Policy from time to time.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy will be effective when posted on the Service Desk or at the designated Privacy Policy location, unless otherwise required by applicable law.

The "Revised" date at the beginning of this Privacy Policy will be updated to reflect material revisions.

Where required by law, we will provide additional notice or obtain consent before implementing changes.

Transfer of Data

Rolka Loube is located in the United States.

Information collected through the Service Desk may be maintained or processed using computers, servers, or other technology infrastructure operated by Rolka Loube or its authorized service providers.

Depending on the infrastructure and service arrangements used to operate the Service Desk, information may be stored or processed in the United States or other locations where authorized service providers maintain facilities.

Where applicable, Rolka Loube will handle transfers of Personal Data in accordance with relevant legal and contractual requirements.

By using the Service Desk, you acknowledge that information submitted through the Service Desk may be processed as described in this Privacy Policy, subject to applicable law.

Extraordinary Circumstances That May Result in Disclosure of Information

Extraordinary circumstances may arise that would require or justify Rolka Loube disclosing information collected through the Service Desk.

Such circumstances include, but are not limited to, Rolka Loube's good faith belief that disclosure is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of Rolka Loube, its clients, or the Service Desk

• Prevent or investigate possible wrongdoing in connection with the Service Desk

• Protect the personal safety of Service Desk users or the public

• Investigate suspected security incidents, fraud, or unauthorized access

• Protect against legal liability.

Any such disclosure will be made in accordance with applicable legal requirements.

Your Privacy Rights Under State Law.

If you are a resident of a state that has enacted comprehensive consumer data-privacy legislation, you may have certain rights regarding your Personal Data, depending on the applicable law and any relevant exceptions.

These rights may include:

• The right to request access to the Personal Data we have collected about you.

• The right to request correction of inaccurate Personal Data.

• The right to request deletion of Personal Data, subject to applicable exceptions.

• The right to request data portability, where applicable.

• The right to opt-out of certain uses of Personal Data, such as targeted advertising or the sale or sharing of Personal Data, where applicable.

• The right to non-discrimination for exercising applicable privacy rights.

• The right to appeal a denial of a privacy request, where provided by applicable law.

Certain rights may be limited by legal exemptions, government program requirements, contractual obligations, records-retention requirements, or other applicable provisions.

To exercise applicable privacy rights, you may submit a verifiable consumer request by contacting us at:

·         Phone: (717) 585-6605

·         Email: webadmin@rolkaloube.com

We may take reasonable steps to verify your identity and authority to make a request before providing access to, correcting, or deleting Personal Data.

We will process requests in accordance with applicable law and our internal procedures.

We may deny or limit a request where we cannot reasonably verify the requester's identity or where an applicable law permits or requires us to retain or otherwise process the information.

Additional information regarding comprehensive consumer data-privacy legislation in the United States is available through the International Association of Privacy Professionals (IAPP):

https://iapp.org/resources/article/us-state-privacy-legislation-tracker/#state-privacy-law-directory

Access to specific information and data portability rights, Data Portability and Deletion Rights

Subject to applicable law, you may request that Rolka Loube disclose certain information regarding the collection and use of your Personal Data over the past twelve (12) months.

You may also request correction or deletion of Personal Data maintained through the Service Desk, where such rights apply.

Requests involving Service Desk ticket information may be subject to applicable records-retention obligations, government program requirements, security considerations, and other legal exceptions.

To submit a verifiable request, please contact us by:

• Phone: (717) 585-6605

• Email: webadmin@rolkaloube.com

Rolka Loube will review and respond to requests in accordance with applicable law.

Definitions

Business Information — Information collected from you, your organization, or other authorized sources that relates to your business or organizational relationship with Rolka Loube. This may include your business email address, business telephone number, company or organization name, business affiliation, and other non-sensitive business information relevant to a support request.

Cookies — Small files stored on your device that may include an anonymous unique identifier. Cookies are sent to your browser from the Site and stored on your device. The term "Cookies" includes other similar tracking technologies, such as beacons, tags, and scripts, that may be used to collect information or improve and analyze Service Desk services.

Information — Collectively, the Personal Data, Business Information, Ticketing Information, Cookies, and Usage Data collected or generated through the Service Desk.

Personal Data — Any information relating to an identified or identifiable living individual, including information that could reasonably be used to identify that individual. Depending on applicable law, this may include names, business email addresses, IP addresses, or other identifying information.

Personally Identifiable Information (PII) — Information that can identify an individual directly or indirectly, whether by itself or in combination with other information. For purposes of the Service Desk's submission restrictions, users are prohibited from submitting sensitive or unnecessary PII, while basic business contact information reasonably necessary for support requests is permitted.

Sensitive Data — Information requiring heightened protection because of its personal, financial, medical, authentication-related, confidential, or regulated nature. Examples include Social Security numbers, financial account numbers, passwords, government identification numbers, and protected health information.

Service Providers — Third-party companies and individuals that Rolka Loube may use to provide, host, administer, maintain, or support the Service Desk, perform Service Desk-related services, or analyze how the Service Desk is used.

Ticketing Information — Information submitted, collected, generated, or maintained in connection with Service Desk support requests. This includes ticket subjects, descriptions, requester contact information, comments, communications, attachments, ticket identifiers, status information, timestamps, assignments, resolution details, and associated administrative records.

Usage Data — Data collected automatically from use of the Service Desk or generated through its supporting systems. Examples may include IP addresses, browser types and versions, pages visited, access dates and times, device identifiers, session information, and diagnostic data.

CONTACT US

If you have any questions about this Privacy Policy, please contact us:

Rolka Loube
4050 Crums Mill Rd.
Suite 303
Harrisburg, PA 17112
United States
Phone: (717) 585-6605
webadmin@rolkaloube.com